Submission on Glendell Continuation Project (part of Mt Owen Complex)
by Alec Roberts (thanks to George Woods for the great info supporting this submission)
Objection to Project
The present scientific consensus is that the earth's climate is warming due to human activity (https://climate.nasa.gov/scientific-consensus/), and the negative impacts of increased greenhouse gas emissions are measurable globally and nationally. The government is responsible for the health and wellbeing of its citizens and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the impact on Australians and the wealth of the nation.
NSW Climate Change Policy Framework details NSW Government’s objective to achieve net-zero emissions by 2050. This long-term objective “sets a clear statement of government’s intent, commitment and level of ambition and sets expectations about future emissions constraints that will help the private sector to plan and act.” The Policy Framework states that the NSW Government will investigate how to embed consideration of climate change mitigation and adaptation across government operations including service delivery, infrastructure, purchasing decisions and regulatory frameworks. Furthermore, it states that Agencies will undertake additional policy investigation for sectors with significant opportunities and risks, including primary industries emissions and adaptation (Department of Primary Industries).
The Glendell Continuation Project will result in 230.8 million tonnes of greenhouse gases over the life of the project. This is in addition to the greenhouse pollution from the rest of the Mount Owen complex.
The assessment admits that the project is consistent with the IPCC’s “high emissions A2 emission trajectory scenario.” This is a shocking admission and all the more shocking that it did not prompt the company to withdraw the proposal. The A2 scenario is projected to result in warming by approximately 3.4C by 2100. As the greenhouse assessment outlines, this scenario is associated with increased maximum temperatures, hot days and severe fire danger days.
This project is not consistent with NSW’s climate change policy, the principle of inter-generational equity nor the public interest, as it clearly assumes failure to meet the Paris Agreement temperature goals and worsening climate change impacts for New South Wales.
There is a cumulative issue relating to air quality in the Upper Hunter that needs attention. Average levels of coarse particle pollution in the Hunter Valley have increased at a rate higher than the rest of NSW
Air quality in the local area has been deteriorating over time, reaching 470 air quality alerts in 2019 prior to the bushfires.
The top three for PM10 particulate levels of air pollution in NSW are in the local area.
This air pollution contributes to heart disease, stroke, deaths, diabetes, low birth weight for babies, restricted lung growth in children, lung cancer in non-smokers, asthma and emphysema.
The expansion will exacerbate an already dire set of circumstances with respect to air quality and health issues in the local area.
The mine assessment admits that most air quality monitoring sites in the vicinity of Glendell Mine have experienced at least one day above the national standards for PM10 particulate pollution in the past seven years and some exceeded annual average thresholds in the last two years. Camberwell and Singleton also exceeded the PM2.5 criterion last year.
But the EIS uses a low pollution year, 2014, as its base year, setting background air pollution levels at less than half of the pollution concentrations experienced in the vicinity more recently. Nevertheless, the assessment shows intensification of PM2.5 and PM10 air pollution in Camberwell and surrounding areas.
This project further extends mining in a heavily-mined area, exacerbating water loss.
Baseline monitoring has identified water level drawdown within the coal seams due to the cumulative impact of approved activities that surround the proposed Glendell Pit Extension. The Environmental assessment noted
“The proposed Glendell Pit Extension will further depressurise the geological strata directly intersected by the mining activities. The Project will create a zone of drawdown around the mining activity where groundwater levels will decline during the mine life. The depressurisation will also create an area of low pressure within the groundwater system centred on the Glendell Pit Extension that will encourage groundwater to flow through coal seams towards the mining area drawing groundwater from the adjacent water sources.”
The mine’s groundwater assessment shows that dramatic drawdown of the coal seam under the Bowman’s Creek alluvium propagates upward into the alluvium and causes drawdown and loss of surface water.
This adds to stress already being experienced in the area from other mines, and the groundwater assessment also shows cumulative draw down of over 2 metres in the alluvium during the proposed mining operations.